This appeal involves five parcels of land in the Township of Vernon which are part of the 35,000-acre Pequannock Watershed purchased by Newark in 1900 to provide a water supply. Three of the parcels are substantial in size, measuring over 1,000 acres. Vernon's assessments of the five tax lots for 1973, 1974, and 1976 were as follows:

Per Acre

Block Lot Acreage Assessment Assessment

203 1 1, 998 $1,000 $1,998,000

203 1A 292 1,100 321,000

210 7 1,588 850 1, 348,800

240 2 1,506 512 771,000

240 5 40 1,550 62,000

5,424 $4,500,800

As of October 1, 1972, effective for the tax year 1973, all of the subject properties under appeal were zoned A-1 Residential District. On March 3, 1973, however, effective for the tax year 1974, Vernon rezoned the properties to Conservation District, thus severely restricting the permitted uses of the land.

Newark appealed the assessments imposed for 1973, 1974 and 1976 to the Division of Tax Appeals (now Tax Court of New Jersey). The cases were ...

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